Author Topic: RLUIPA Law Suit Filed by Church of Scientology of Georgia  (Read 99249 times)

Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #80 on: November 22, 2010, 11:14 »
What you might wish to consider, at least for future use, is a Firefox plugin called RECAP. What this does is to mirror a copy of documents you retrieve from PACER to a publically-available archive, where the documents can be retrieved for free.

Welcome to Reaching for the Tipping Point, Guy. 

Looks like a worthwhile plugin.  The FAQ is here: https://www.recapthelaw.org/about/

Thanks.

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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #81 on: December 24, 2010, 22:40 »
Edit: I am adding the descriptions below the filenames for to make it easier to decide what to read (and to keep up with what I've read).  If anyone else would like to contribute brief descriptions and/or interesting tidbits, I'll edit them into the main post.  Discussion should stay as separate posts. 

Edit 2: Also reorganizing to put more in order.  Scroll down.

New documents in the RLUIPA case against the City of Sandy Springs:
Original list:
http://alley.ethercat.com/storage/RLUIPA/08-11-2010_Supplement_Plaintiff_Init_Disclosures.pdf
http://alley.ethercat.com/storage/RLUIPA/09-02-2010_Certificate_of_Service.pdf
http://alley.ethercat.com/storage/RLUIPA/09-21-2010_Certificate_of_Service.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010-Brief_37-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_37-2-Brief_Part_2.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_37-3_COS_Theory_of_Recovery.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_37-4_COS_Statement_of_Material_Facts.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_37_COS_Motion_for_Summary_Judgement.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38-1_Affidavit_of_Allan_Cartwright.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38-2_Affidavit_of_Deb_Danos.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38-3_Affidavit_of_Robert_Wright.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38-4_Affidavit_of_Nancy_Leathers.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38_Notice_of_Filing_Exhibits-Copy.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-1_Exhibit_G3.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-2_Exhibit_G4.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-3_Exhibit_G5.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-4_Exhibit_G6.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-5_Exhibit_H.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits-38.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_39.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_40.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_E-39-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_E-39-2.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_F_39-3.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_G1-39-5.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_G2-39-6.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_G_39-4.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-10.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-5.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-6.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-7.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-8.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-9.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A10.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A11.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A12.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A13.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A14.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A15.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A16.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A17.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A18.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A19.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A2.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A20.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A21.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A22.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A23.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A3.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A4.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A5.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A6.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A7.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A8.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A9.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-42-A1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-42-A2.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-42-A3.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-42.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44-2.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44-3.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44-4.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44-5.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_45_Notice_of_Manual_Filing.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_46-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_46.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_47-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_47.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_48-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_48.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_49-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_49.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_50-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_50.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_51-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_51.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_52-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_52.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_54.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_55.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_56.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_Defendents_Motion_for_Summary_Judgement-43-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_Defendents_Motion_for_Summary_Judgement-43.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_Defendents_Statement_of_Material_Facts_Not_in_Dispute-43-2.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_Defendents_Statement_of_Material_Facts_Not_in_Dispute-43-3.pdf
http://alley.ethercat.com/storage/RLUIPA/12-22-2010_53-1.pdf

Reorganized list with descriptions:

http://alley.ethercat.com/storage/RLUIPA/08-11-2010_Supplement_Plaintiff_Init_Disclosures.pdf
http://alley.ethercat.com/storage/RLUIPA/09-02-2010_Certificate_of_Service.pdf
http://alley.ethercat.com/storage/RLUIPA/09-21-2010_Certificate_of_Service.pdf

http://alley.ethercat.com/storage/RLUIPA/12-15-2010-Brief_37-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_37-2-Brief_Part_2.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_37-3_COS_Theory_of_Recovery.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_37-4_COS_Statement_of_Material_Facts.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_37_COS_Motion_for_Summary_Judgement.pdf

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38_Notice_of_Filing_Exhibits-Copy.pdf
(Duplicate of below)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits-38.pdf
(Administrivia - This is the Notice of Filing Exhibits.)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38-1_Affidavit_of_Allan_Cartwright.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38-2_Affidavit_of_Deb_Danos.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38-3_Affidavit_of_Robert_Wright.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38-4_Affidavit_of_Nancy_Leathers.pdf

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-5.pdf
(Zoning Ordinance 18.2.1)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-6.pdf
(Some pages from the rezoning meeting packets)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-7.pdf
(Some pages from the rezoning meeting packets)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-8.pdf
(Some pages from the rezoning meeting packets discussing the parking study)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-9.pdf
(Alternate conditions proposed at the Planning Commission Meeting September 17, 2009)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-10.pdf
(Alternate conditions proposed at the Mayor and City Council Meeting October 20, 2009)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_39.pdf
(Administrivia)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_E-39-1.pdf
(Kimley-Horn Traffic Study Part 1)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_E-39-2.pdf
(Kimley-Horn Traffic Study Part 2)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_F_39-3.pdf
(Kimley-Horn Traffic Study Addendum for Buffalo, NY)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_G_39-4.pdf
(Exhibit "G", October 14, 2010 Deposition Transcript of Nancy Leathers, Pages 173, 174, 179-185, 199-201)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_G1-39-5.pdf
(Exhibit "G-1", Defendants' Response to Plaintiff's Second Discovery Requests)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_G2-39-6.pdf
(Exhibit "G-2", Deposition Exhibit No. 28, Part of the Sandy Springs Zoning Ordinance concerning Off Street Parking and Loading)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_40.pdf
(Administrivia)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-1_Exhibit_G3.pdf
(This is the rezoning packet for Kadampa Meditation Center which is referred to in other documents.)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-2_Exhibit_G4.pdf
(This refers to the rezoning for Lutheran Church of the Apostles.)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-3_Exhibit_G5.pdf
(Congregation Beth Tiffilah)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-4_Exhibit_G6.pdf
(Zainabia Islamic Education Center)

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-5_Exhibit_H.pdf
(Exhibit 16 to Deposition of Robert Wright: Scientology Classification Gradation & Awareness Chart)

http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A2.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A3.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A4.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A5.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A6.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A7.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A8.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A9.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A10.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A11.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A12.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A13.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A14.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A15.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A16.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A17.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A18.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A19.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A20.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A21.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A22.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-41-A23.pdf

http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-42-A1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-42-A2.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-42-A3.pdf
http://alley.ethercat.com/storage/RLUIPA/12-16-2010_Deposition_Nancy_Leathers-42.pdf

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_Defendents_Motion_for_Summary_Judgement-43.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_Defendents_Motion_for_Summary_Judgement-43-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_Defendents_Statement_of_Material_Facts_Not_in_Dispute-43-2.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_Defendents_Statement_of_Material_Facts_Not_in_Dispute-43-3.pdf

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44.pdf
(DEFENDANTS’ NOTICE OF FILING ORIGINAL DISCOVERY AND REQUEST FOR FILING ORIGINAL DISCOVERY)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44-1.pdf
(Deposition of Deb Danos, DSA CoS-Ga., May 19, 2010)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44-2.pdf
(Deposition of Bob Wright, in charge of construction of the Ideal Orgs, August 6, 2010.  Kendrick Moxon was also present at the request of deponent.)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44-3.pdf
(Deposition of Mark Moore on behalf of plaintiff, May 27, 2010.  Mark Moore is the traffic engineer for Sandy Springs.)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44-4.pdf
(Defendant's Response to Plaintiff's First Interrogatories)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_44-5.pdf
(Defendant's Response to Plaintiff's Second Interrogatories and Request for Production of Documents and Notice to Produce to Defendants)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_45_Notice_of_Manual_Filing.pdf
(COME NOW the City of Sandy Springs, Georgia, and its named elected officials, Defendants in the above-styled action, and notify the Court that sealed original copies of the following documents were filed conventionally because they contain oversized, graphic exhibits that Defendants did not have the capacity to convert to digital format and upload to the CM/ECF system: A. Deposition of Deborah Quinn Danos taken May 19, 2010. B. Deposition of Robert Michael Wright taken August 6, 2010. Respectfully submitted this 21st day of December, 2010.)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_46.pdf
(DEFENDANTS’ NOTICE OF FILING CERTIFIED DOCUMENTS and CERTIFICATE OF SERVICE)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_46-1.pdf
(Transcription of Audio CD in Re: Sandy Springs, Georgia Planning Commission RZ09-001/CV09-006 November 19, 2009.  Note: This meeting can be viewed in 7 parts, starting here: http://www.youtube.com/Reach4theTippingPt#p/u/36/2t_hhXu_aqo )

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_47.pdf
(DEFENDANTS’ NOTICE OF FILING CERTIFIED DOCUMENTS and CERTIFICATE OF SERVICE)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_47-1.pdf
(Transcription of Audio CD in Re: 19 Sandy Springs, Georgia City Council 20  RZ09-001/CV09-006 December 15, 2009.  Note: This meeting can be viewed in 10 parts, starting here: http://www.youtube.com/Reach4theTippingPt#p/u/29/O5Xy_Xs3wiw )

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_48.pdf
(DEFENDANTS’ NOTICE OF FILING CERTIFIED DOCUMENTS and CERTIFICATE OF SERVICE)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_48-1.pdf
(Meeting minutes of the Regular Meeting of the City of Sandy Springs City Council held Tuesday, October 20, 2009 and Meeting minutes of the Regular Meeting of the City of Sandy Springs City Council held Tuesday, December 15, 2009)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_49.pdf
(DEFENDANTS’ NOTICE OF FILING CERTIFIED DOCUMENTS and CERTIFICATE OF SERVICE)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_49-1.pdf
(City of Sandy Springs Zoning Ordinance)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_50.pdf
(DEFENDANTS’ NOTICE OF FILING CERTIFIED DOCUMENTS and CERTIFICATE OF SERVICE)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_50-1.pdf
(More of the City of Sandy Springs Zoning Ordinance)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_51.pdf
(DEFENDANTS’ NOTICE OF FILING CERTIFIED DOCUMENTS and CERTIFICATE OF SERVICE)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_51-1.pdf
(More of the City of Sandy Springs Zoning Ordinance)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_52.pdf
http://alley.ethercat.com/storage/RLUIPA/12-21-2010_52-1.pdf
(Yet more Zoning Ordinance)

http://alley.ethercat.com/storage/RLUIPA/12-22-2010_53-1.pdf
(Consent Order to extend Defendant's Response time to Plaintiff's Motion for Summary Judgement)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_54.pdf
(DEFENDANTS' NOTICE OF MANUAL FILING)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_55.pdf
(Filing by BENNETT REPORTING, INC. regarding Deborah Quinn Danos deposition)

http://alley.ethercat.com/storage/RLUIPA/12-21-2010_56.pdf
(Filing by BENNETT REPORTING, INC. regarding Robert Michael Wright deposition)


How nice of them to give us something to read over the Christmas holidays.   cU#__

Certainly some of these make for interesting reading.
« Last Edit: December 29, 2010, 22:00 by ethercat »
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Offline Mary_McConnell

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #82 on: December 25, 2010, 00:47 »
 :o~! You sure have been busy!! Have to set aside and hour tomorrow nite to read them!
I am a volunteer advocate for victims of the Narconon scam. I am a former scientologist. I post anonymously. Mary McConnell is my long time nom de plume. Feel free to contact me for assistance in righting the wrongs.

Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #83 on: December 25, 2010, 20:39 »
http://alley.ethercat.com/storage/RLUIPA/12-15-2010-Brief_37-1.pdf
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_37-2-Brief_Part_2.pdf

Finally, this is admitted openly:
Quote
The Church proposes locating the chapel in the basement of the building because the existing building is not engineered and constructed to allow a conventrated assembly of people on any other floor of the building.  Denying the Church the ability to utilize the basement would require the Church to revise its existing renovations plans (civil plans have been completed) and re-engineer the structural support of the building, which would be prohibitively expensive.

More expensive than the RLUIPA lawsuit?

Note that, in all fairness, I have no idea how much structural re-engineering would cost , nor any idea of how much the RLUIPA lawsuit is costing.  But then, I would have picked a building that was already structurally sound enough to do what I wanted to do with it to begin with.  I would have done my research first, instead of chanting the "make it go right" mantra which seems quite ineffectual in the real world.

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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #84 on: December 25, 2010, 22:08 »
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_37-4_COS_Statement_of_Material_Facts.pdf

Quote
28.
Scientology churches also hold congregational services on Sundays, religious holidays, and certain other occasions.

Galloway had said during the rezoning meetings that they didn't hold a congregational service on Sunday, that they were a non-traditional church.

Quote
29.
Scientologists believe that the expansion and dissemination of the religion is necessary to salvage human civilization.

So we can conclude that if the "Church" is successful in doing this, they will need more parking spaces.  And because humans would still be living in caves and killing each other with sharpened sticks, if not for scientology.

Quote
30.
All Scientology churches have a religious obligation to reach out to their community to spread the word of Scientology so that new members may pursue the path to spiritual enlightenment.

Hence, front groups.

Quote
31.
Scientology churches, therefore, are mandated to include large Public Display areas, including audio-visual presentations on the religion and its social betterment campaigns such as for human rights, drug and alcohol addiction prevention, literacy and scholastic improvement.

The Church of Scientology is a modern and technology-oriented "church" (read as: needs lots of money). 

Human rights: CCHR - taking away your human right to choose to take psychiatric medication if you need and/or desire.  (because scientologists "are the authorities on the mind", right Tom?)

Drug and alcohol addiction prevention: Narconon - Trying to get you off drugs or alcohol and hook you on scientology instead, if they don't kill you or seriously damage your health first.

Literacy: The World Literacy Crusade, Hollywood Education and Literacy Project (HELP) - You have to be able to read to do scientology, you'll also have to be able to pay for the massive amount of texts that Hubbard wrote or babbled into a tape recorder to be transcribed into books the "parishioners" must pay for. (So you might also need World Institute of Scientology Enterprises aka WISE to make that money.)

Scholastic improvement: Applied Scholastics - Trying to grab some government dollars/pounds/pesos/yen/etc. by putting scientology into the school system, based on the principle that if you get 'em young, they're easier to teach how to think, the scientology way.

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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #85 on: December 25, 2010, 22:27 »
:o~! You sure have been busy!! Have to set aside and hour tomorrow nite to read them!

'Twasn't me who filed all this stuff with the court, thank goodness!

An hour?!   (OoO)  It's gonna take me 10 times that.  Maybe I should get some Study Tech?   :P
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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #86 on: December 25, 2010, 22:41 »
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38-3_Affidavit_of_Robert_Wright.pdf

Quote
4.
Based on my study of CSI's files and my general knowledge of my position, I am informed and believe that beginning in 2003, CSI embarked on a program to create what we call Ideal Central Organizations or "Ideal Orgs."  (For decades, Scientology churches have been referred to colloquially as "Orgs," short for organizations.)  An Ideal Class V Organization holds and houses all of the functions required for a Class V Church, according to the Scientology Scriptures, and is able to actually deliver all of those functions and services.  Even many today, an estimated 90% or more) of our existing Church buildings are not of the correct size to house all the functions.  For that reason, for the last five (5) or six (6) years, Scientology churches around the world have been purchasing new buildings so that they can provide all the needed programs and functions of the church.

Quote
7.
In 2003, CSI determined that from that point forward, all future Scientology churches would be designed and built as Ideal Church Organizations.  At first, there were no standards in place.  We were trying out different concepts and evolving those concepts as we went along.  The first pilot Ideal Church was in Tampa.

So this was all dictated by CSI and not Hubbard?  What a surprise.   ::)
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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #87 on: December 25, 2010, 23:16 »
Making some notes about which of these are interesting or not.

http://alley.ethercat.com/storage/RLUIPA/12-15-2010_38-4_Affidavit_of_Nancy_Leathers.pdf
This consists of several pages from Nancy Leathers' deposition, might as well read the whole deposition.

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-1_Exhibit_G3.pdf
This is the rezoning packet for Kadampa Meditation Center which is referred to in other documents.

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-2_Exhibit_G4.pdf
This refers to the rezoning for Lutheran Church of the Apostles.

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-3_Exhibit_G5.pdf
Congregation Beth Tiffilah

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-4_Exhibit_G6.pdf
Zainabia Islamic Education Center

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_40-5_Exhibit_H.pdf
Exhibit 16 to Deposition of Robert Wright: Scientology Classification Gradation & Awareness Chart

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits-38.pdf
Administrivia

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_39.pdf
Administrivia

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_40.pdf
Administrivia

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_E-39-1.pdf
Kimley-Horn Traffic Study Part 1

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Notice_of_Filing_Exhibits_E-39-2.pdf
Kimley-Horn Traffic Study Part 2
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Offline Mary_McConnell

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #88 on: December 25, 2010, 23:57 »
Thanks for the notes on the pdfs and the Ideal Org origin comments! It sure looks like a Miscavige creation from the sounds of it.
I am a volunteer advocate for victims of the Narconon scam. I am a former scientologist. I post anonymously. Mary McConnell is my long time nom de plume. Feel free to contact me for assistance in righting the wrongs.

Offline SocialTransparency

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #89 on: December 26, 2010, 08:31 »
 Within Allan Cartwrights affidavit, and his explanation of the tenets of scientology, nowhere do I see mention use of the E-Meter in the auditing process. Is not the E-Meter the foundation in which a scientologist gains knowledge of one self? I wonder why Mr Cartwright failed to make reference to this oh so holiest of holy devices?

 If one were to draw vague religious parallels here, would not the E-Meter be the rock on which the CULT built its alleged church?

Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #90 on: December 26, 2010, 12:05 »
Within Allan Cartwrights affidavit, and his explanation of the tenets of scientology, nowhere do I see mention use of the E-Meter in the auditing process. Is not the E-Meter the foundation in which a scientologist gains knowledge of one self? I wonder why Mr Cartwright failed to make reference to this oh so holiest of holy devices?

I guess he didn't consider it relevant to parking issues or religious discrimination.  I would probably agree with him there.
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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #91 on: December 26, 2010, 12:19 »
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-5.pdf
Zoning Ordinance 18.2.1

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-6.pdf
Some pages from the rezoning meeting packets

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-7.pdf
Some pages from the rezoning meeting packets

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-8.pdf
Some pages from the rezoning meeting packets discussing the parking study

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-9.pdf
Alternate conditions proposed at the Planning Commission Meeting September 17, 2009

Quote
http://alley.ethercat.com/storage/RLUIPA/12-15-2010_Sandy_Springs_Zoning_38-10.pdf
Alternate conditions proposed at the Mayor and City Council Meeting October 20, 2009

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Offline mefree

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #92 on: December 26, 2010, 13:00 »
Some very interesting reading starting with 44-1

INDEX TO EXAMINATIONS
2 DEBORAH QUINN DANOS PAGE
3 Examination by Ms. Henderson................. 4
4
5
6
7 DEFENDANT'S EXHIBITS
8 EXHIBIT DESCRIPTION PAGE
9 1 Limited Warranty Deed 28
10 2 Property and Boundary Survey 28
11 3 Plans (full size) 52
12 4 Floor Plans 53
13 5 Certificate of Zoning 85
14 6 Parking Evaluation 89
15 7 7/15/09 Letter from J. Walker to W. 92
16 Galloway with attachments
17 8 Academy/Div 6 and Staff Roll Sheets 118
18 9 Events Call-In 118
19
20
21 (Defendants' Exhibit No. 3 was retained by Ms.
22 Henderson.)
23
24
25

Just a snippet:
Quote
All right. What are your current duties with the Scientology Church of Georgia? First of all, what 16 is your title?
A: My title is director of special affairs, which is essentially a community liaison role.
Q: Okay. And specifically what are your duties?
A: Specifically I oversee the social betterment programs, the community programs, and I am the media contact person. So public relations. I am the legal liaison. And that's essentially everything.
Q: Those are very diverse areas.
A: They are indeed. Essentially I handle everything that goes on outside of the church.
Q:Okay.
A: I mean, that's kind of how it's designated.
Q: You're the face of the church to the outside world in the Georgia community?
A: Essentially, yes.
The ultimate authority must always rest with the individual's own reason and critical analysis.
-Dalai Lama

Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #93 on: December 26, 2010, 15:48 »
I thought this was funny:
Quote
20 A Did I finish all my thoughts? Was I in the
21 middle of something?

***:|

Quote
25 Q Okay. Are there rites or rituals for
1 officially becoming part of a Scientology organization?

Yeah!  Paying money!   :D 

Quote
23 Q Okay. Is there an annual fee for belonging to
24 the International Association of Scientologists?

25 A There is not. There is not. One would be
1 asked to renew at the end of their, say, six-month
2 membership, one would be asked to purchase an annual
3 membership
. It's totally up to you if you want to do
4 that or not.
5 Q Okay.
6 A If you do, you maintain the privileges of that
7 membership which is, of course, discounted rates on
8 books and services and the magazine and all the stuff.
9 And if you don't, fine.
10 Q And if you don't, you can still obtain those
11 materials; you just don't obtain them at a discounted
12 price?
13 A Correct.

There is not an annual fee, but when the 6 months free membership is up, "one would be asked to purchase an annual membership"?  And you don't purchase it for an annual fee?  If not for an annual fee, what, pray tell, would one purchase an annual membership with?    /x$$x/

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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #94 on: December 26, 2010, 15:52 »
From the first part of the Deb Danos deposition:

Quote
8 Q Okay. All right. And then when you say 100
9 active, tell me a little bit more about what that means.
10 A I mean 100 of people who have recently -- and
11 I say recently, like, say, within the last year -- are
12 participating in services at the organization. So that
13 would be course work, extension courses, or courses in
14 the Academy or counseling or in some way involved in our
15 community service programs
, you know, people who are
16 actively doing something.

Would that include people working for Narconon who are not otherwise attending services?
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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #95 on: December 26, 2010, 16:06 »
This may be helpful in someone's lawsuit somewhere, concerning David Miscavige's degree of control and the levels of the corporate structure:

Quote
5 Q The Church of Scientology International, where
6 is that based?
7 A Los Angeles.
8 Q And how is it organized to the best of your
9 understanding?
10 A I don't know that I can actually answer that
11 question.
12 Q All right. Who controls that organization?
13 A David Miscavige is the chairman of the board
14 of the Religious Technology Center. Now, there is an
15 affiliation between the RTC and the Church of
16 Scientology International, but I am not 100 percent
17 aware of the corporate structure of those groups.
18 I can tell you that David Miscavige is the
19 ecclesiastic leader of the church and a good bit of the
20 church direction comes from him.
21 Q You mentioned the initials RTC. Tell me again
22 what that stands for.
23 A Religious Technology Center.
24 Q And you're saying that's different than CSI?
25 A It is different than CSI, yes. The RTC is the
1 holder of the works of L. Ron Hubbard.
2 Q What is the Georgia church's relation to CSI,
3 if any?
4 A Well, essentially we are hierarchical in
5 structure. And CSI is the body -- really the governing
6 body of, you know, ecclesiastically speaking, of the
7 churches around the world.
8 Q All right. Is there any intermediate level
9 going from CSI to the Georgia church? Are there
10 churches that would be in the middle of that hierarchy?
11 A There is. There's a Continental -- what's
12 called a Continental Liaison Organization, one on the
13 east coast and one on the west coast. And that is the
14 intermediary governing body.
15 Q I assume because we're in Atlanta that you
16 would go through the east coast Continental Liaison.
17 Where is that located?
18 A New York.
19 Q Okay. And is that the next step down under
20 CSI?
21 A Yes.
22 Q Okay. And then is there a further step down
23 from the Continental Liaison body to the Georgia church?
24 A No.

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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #96 on: December 26, 2010, 18:31 »
Something of interest to anyone researching the Ideal Orgs and how they're purchased:
Quote
16 Q '7. All right. We're at 2007. And then it's
17 been two years since the Sandy Springs property was
18 purchased. Is that property vacant and available at
19 that point?
20 A It was vacant, yes.
21 Q And why did the Georgia church choose not to
22 try to move toward use of the Sandy Springs property at
23 that time?
24 A At that time we were involved in repaying a
25 loan that was made by CSI to purchase the building.
1 Q Okay.
2 A Fundraising to repay that loan and to further
3 handle the renovations that were needed on the building.
4 Q Okay. So the Roswell Road building was
5 purchased with money from CSI?
6 A Originally.
7 Q Which then had to be repaid?
8 A Correct.
9 Q And has that purchase price been repaid in its
10 entirety?
11 A Yes, it has.
12 Q So the Georgia church now owns the Roswell
13 Road building free and clear?
14 A That's correct.
15 Q Okay. Did CSI also advance money for
16 renovation of the Roswell Road building?
17 A No.

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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #97 on: December 26, 2010, 18:34 »
LOL!
Quote
5 Q Understandably so. At the current time would
6 you describe for me -- we're going to work on describing
7 the Dunwoody facility.
8 A Okay.
9 Q I understand that that building is in an
10 office park; is that correct?
11 A Correct.
12 Q And how large is the space square footage wise
13 that the Dunwoody facility currently occupies?
14 A Approximately 11,000 square feet.
15 Q How much space is available for classes in
16 that facility at the present time?
17 A Gosh, square footage wise or percentage wise?
18 Q How about number of courses. How many courses
19 can be offered at once in the Dunwoody facility?
20 A Well, that --
21 Q As it's set up. Is that easier?
22 A That doesn't help.
23 Q That doesn't help.
24 A Because what we have at the Dunwoody facility
25 is one large course room that has a temporary dividing
1 wall in it and another alcove. So it's a bit of a
2 makeshift into three separate areas -- four, actually.
3 Q And the four areas that that classroom is
4 divided into, does that account for the group portion of
5 the class meeting as well as the individual meeting
6 portions?
7 A It accounts for only on the group study.
8 Yeah. The individual -- we have an area that is divided
9 off to handle the one-on-one activity.
10 Q Okay. And is there an area that's also
11 available for counseling activity in the Dunwoody
12 facility?
13 A Yes.
14 Q And how large, how many offices are available
15 for counseling in the Dunwoody facility?
16 A Three.
17 Q So getting back to my question, which I don't
18 mean to be difficult, but we're still trying to figure
19 how to talk to one another.

Oh, yeah, that Scientology Communication course really does a lot of good!  Try one from the local college next time.  College works and it helps people.
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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #98 on: December 26, 2010, 18:43 »
Quote
9 Q And how many additional volunteers does the
10 Georgia Scientology Church utilize on, say, on a weekly
11 basis?
12 A We probably have 10 or 12 volunteers who will
13 come in on a weekly basis, but they vary widely.
14 Q What kinds of activities would those
15 volunteers be allowed to do?
16 A They would help typically on our social
17 betterment campaigns, drug-free world, youth for human
18 rights, the way to happiness, volunteer ministers, or
19 they could come in and participate in any number of
20 projects that we have ongoing that are going to prepare
21 us to move into an ideal org situation. One of which is
22 getting our student and parishioner files in order.

Does that include access to the allegedly secret "auditing folders"?

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Offline ethercat

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Re: RLUIPA Law Suit Filed by Church of Scientology of Georgia
« Reply #99 on: December 26, 2010, 19:06 »
Thanks for the notes on the pdfs and the Ideal Org origin comments! It sure looks like a Miscavige creation from the sounds of it.

More on the Ideal Org origin from Deb Danos:
Quote
11 Q All right. Are you familiar with the concept
12 of ideal organizations?
13 A Yes.
14 Q How long has that concept of ideal
15 organizations been in effect within the Scientology
16 community?
17 A I think Hubbard did some writing on it quite a
18 number of years ago in a bit of an abstract fashion, you
19 know, in direct naming this is what an ideal org should
20 be. It doesn't define space. But it talks about what
21 products one will get and what would be the environment
22 and, you know, kind of like the general feel and that --
23 it's a bit more abstract.
24 However, the ideal org evolution as we refer
25 to it did not really come into our purview here locally
1 until 2005 with the release of what we call the basic
2 books. Then we became notified that there had been a
3 project that had been ongoing researching the writings
4 and references and lectures and all of the material of
5 Hubbard to go over and pick out the points that referred
6 to specific requirements of space of an ideal org
7 setting and that this had now culminated into what would
8 be henceforth the template for every church.

Quote
13 Q What information, if any, has CSI provided to
14 Georgia Scientology in terms of what it requires in
15 development of the Roswell Road site?
16 A What we have been given were essentially a set
17 of plans, renderings and plans that were developed by
18 Gensler, which is an engineering design company,
19 architectural, and we were sent a set of renderings and
20 floor plans that were developed for our ideal
21 organization.

Quote
1 Q All right. I'm sorry. International
2 organization. And is it accurate to say that Georgia
3 Scientology is required to develop its facility in
4 accordance with plans that are going to be approved by
5 the international organization?
6 A Yes.
7 Q In other words, Georgia Scientology doesn't
8 have the ability to say "I think we can do this better a
9 different way" and then go off on its own and do
10 something differently?
11 A Well, not without some agreement. We could
12 suggest that.
13 Q Right. On the other hand, if it's not
14 feasible to build according to the first set of plans
15 received from the international organization, then any
16 revision would have to receive approval from the
17 international organization; is that correct?
18 A That is correct.

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